UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
THE
HOME DEPOT, INC.
(Exact Name of Registrant as Specified in Charter)
__________________
Delaware
1-8207
95-3261426
(State or Other Jurisdiction
of Incorporation)
(Commission
File Number)
(IRS Employer
Identification No.)
2455 Paces Ferry Road, N.W., Atlanta, Georgia 30339
(Address of Principal Executive Offices) (Zip Code)
Ron Jarvis, Vice President, Environmental Innovation
(770) 433-8211
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to
which the information in this form applies:
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1
to December 31, 2014.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), The Home Depot, Inc.
has filed this Specialized Disclosure Report (“Form SD”) and Conflict Minerals Report for the calendar year ended
December 31, 2014, and both reports are publicly available at https://corporate.homedepot.com/
CorporateResponsibility/Pages/Conflict-Minerals.aspx.
Item 1.02 Exhibit
The Home Depot Inc.’s Conflict Minerals Report for the calendar year ended December 31, 2014 is filed as Exhibit
1.01 to this Form SD.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report
to be signed on its behalf by the duly authorized undersigned.
THE HOME DEPOT, INC.
By:
Name:
Title:
/s/ Teresa Wynn Roseborough
Teresa Wynn Roseborough
Executive Vice President, General
Counsel & Corporate Secretary
May 29, 2015
(Date)
2
EXHIBIT INDEX
Exhibit
1.01
Description
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
3
Exhibit 1.01
Conflict Minerals Report of The Home Depot, Inc.
for the Calendar Year Ended December 31, 2014
This is the Conflict Minerals Report (“CMR”) of The Home Depot, Inc. for the reporting period from January 1 to
December 31, 2014, in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”).
When we refer to "The Home Depot," the "Company," "we," "us" or "our" in this report, we are referring to The
Home Depot, Inc. and its consolidated subsidiaries.
Overview
We conducted a due diligence process based on the Organization for Economic Cooperation and Development’s
(“OECD’s”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and HighRisk Areas and accompanying Supplements1 (the “OECD Guidance”). Notwithstanding our due diligence process
described herein, we are unable to determine the source of all gold, tantalum, tin and tungsten (“conflict minerals”
or “3TG”) that are necessary to the functionality or production of products we contract to manufacture or whether
these conflict minerals directly or indirectly financed or benefited armed groups in the Democratic Republic of the
Congo and adjoining countries (the “Covered Countries”). The products that we contract to manufacture (the
“Covered Products”) are: Kitchen, Indoor Garden, Paint, Outdoor Garden, Lumber, Flooring, Building Materials,
Plumbing, Electrical, Tools, Hardware, Millwork, Bath, Lighting, and Décor.
Reasonable Country of Origin Inquiry
Introduction
We engaged a third-party service provider to assist us with data collection and aggregation. Together, we worked
with our suppliers to collect information about the presence and sourcing of 3TG used in the Covered Products.
Information regarding the presence of 3TG in a supplier’s products and the source of such 3TG, if present, was
collected and stored using an online platform that utilized the Conflict Minerals Reporting Template (the
“Template”) developed by the Conflict-Free Sourcing Initiative (“CFSI”), which was founded by the Electronics
Industry Citizenship Coalition and Global e-Sustainability Initiative.
Products in Scope
We compiled a list of all Covered Products and worked with our third-party service provider to determine which
Covered Products were in scope for potential use of 3TG and therefore required a Reasonable Country of Origin
Inquiry (“RCOI”). If there was any doubt regarding the material content or the possible use of 3TG, the Covered
Products were included in the RCOI process.
Supplier Engagement
We identified the suppliers with whom we contract directly (“Tier 1 Suppliers”) for the in-scope Covered Products
and contacted them as a part of the RCOI process.
The RCOI began with an introduction email on October 1, 2014, from us to the Tier 1 Suppliers describing our
Conflict Minerals Compliance Program (the “CMCP”) requirements. The Tier 1 Suppliers then were sent a followup email containing registration information and a request to complete the Template and were directed to a Conflict
______________________________
1
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on
Tin, Tantalum and Tungsten and Supplement on Gold, 2013; http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.
Minerals Supplier Resource Center. The Conflict Minerals Supplier Resource Center provides an educational
primer on the CMCP and includes frequently asked questions concerning 3TG mineral tracing.
Non-responsive Tier 1 Suppliers received several follow-up contacts to encourage completion of the Template. The
Tier 1 Suppliers that remained non-responsive were contacted and offered assistance. This assistance included, but
was not limited to, further information about the CMCP, an explanation of why the information was being collected,
a review of how the information would be used, and clarification regarding how the required information could be
provided. Tier 1 Suppliers who failed to respond to our earlier contacts received a re-invitation to the platform.
They were also contacted by our managers who maintain direct relationships with these suppliers and were further
urged to respond in a timely manner.
Due Diligence Program Design
Following completion of the RCOI, we proceeded to the due diligence process to determine the source of any 3TG
in the Covered Products. Our due diligence process was based on OECD Guidance.
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global
supply chain management of minerals from conflict-affected and high-risk areas. This framework consists of the
following elements:
1.
2.
3.
4.
5.
Establish strong company management systems ("Step One");
Identify and assess risk in the supply chain ("Step Two");
Design and implement a strategy to respond to identified risks ("Step Three");
Carry out independent third-party audit of supply chain due diligence at identified points in the
supply chain ("Step Four"); and
Report on supply chain due diligence ("Step Five").
Due Diligence Program Execution
In furtherance of our Conflict Minerals due diligence for 2014, we performed the following measures.
OECD Guidance Step One: Establish strong company management systems
(a) We maintained a policy relating to conflict minerals in our supply chain (“Conflict Minerals Policy”). Our
Conflict Minerals Policy is publicly available at https://corporate.homedepot.com/CorporateResponsibility/
Pages/Conflict-Minerals.aspx. It states:
The Home Depot Conflict Minerals Policy
The Home Depot is committed to ensuring compliance with Section 1502 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act relating to trade in conflict minerals.
The conflict minerals law was enacted to address the exploitation and trade of certain minerals that
contribute to violence and human rights abuses in the Democratic Republic of the Congo and its
neighboring countries in Africa (“Covered Countries”). The law requires public companies to report to the
U.S. Securities and Exchange Commission and disclose information annually about whether the defined
conflict minerals – gold, columbite-tantalite (tantalum), cassiterite (tin), and wolframite (tungsten) – are
necessary to the functionality or production of products they manufacture or contract to manufacture, and,
if so, whether those conflict minerals originate from conflict mines in the Covered Countries.
The Home Depot is committed to the responsible sourcing of materials for our products, and we expect that
our suppliers are likewise committed to responsible sourcing. We expect all suppliers manufacturing our
products to partner with us to provide appropriate information and conduct necessary due diligence in order
to facilitate our compliance with the conflict minerals law. We further expect all suppliers manufacturing
2
our products to adopt sourcing practices to obtain products and materials from suppliers not involved in
funding conflict in the Covered Countries.
The Home Depot provides a Supplier AlertLine for the exclusive use of suppliers to report violations of
company policies, including the Conflict Minerals Policy. Suppliers may contact the Supplier AlertLine at
https://tnw.reportlineweb.com/custom/HDVendorRelations or by using the following toll-free numbers:
• United States and Canada: 1-800-435-3152
• Mexico: 001-888-765-8153
• China: 10-800-711-0714 or 10-800-110-0654
(b) We added the Conflict Minerals Policy to our Supplier Buying Agreement, the contract used with each of
our Tier 1 Suppliers. As such, our Tier 1 Suppliers are obligated to comply with the policy.
OECD Guidance Step Two: Identify and assess risk in the supply chain
(a) After completion of the RCOI, as described above, Tier 1 Suppliers who indicated that 3TG was necessary
to the functionality or production of Covered Products supplied to us were asked to provide information
through the Template regarding the sourcing and origin of the 3TG (i.e., the 3TG smelters or refiners, or
“SORs”). Where a Tier 1 Supplier was unable to provide detailed information about the SORs in its supply
chain, we contacted the applicable suppliers of the Tier 1 Suppliers (“Tier 2 Suppliers”), and subsequent
tiers of suppliers as needed to obtain the necessary information, using the contact procedures explained
above. Collectively, the Tier 1 Suppliers, Tier 2 Suppliers and any suppliers working backward from the
Tier 2 Suppliers are referred to as “Suppliers”.
(b) Based on information provided by the Suppliers, we used the following criteria to determine which Covered
Products that contained 3TG necessary to the functionality or production of such product to include in the
due diligence process:
a. The Suppliers reported sourcing from the Covered Countries (“yes” response to Question 2 of the
Template);
b. The SOR data indicated sourcing from a mine located in the Covered Countries;
c. The SOR reportedly sourced from a mine located in the Covered Countries (based on information
contained within the third-party service provider’s system, from independent certification programs, or
from internet research/available public reports);
d. There was an indication that the SOR sourced from a Covered Country or a country that is known for
smuggling or exporting 3TG out of a Covered Country (a “Level 2 country”); or
e. Information provided about a SOR indicated the origin of the materials was not from a known reserve
for the given metal.
(c) We evaluated the responses we received from Suppliers for plausibility and consistency. Suppliers were
contacted to address issues including implausible statements regarding no presence of 3TG; incomplete
data on their Templates; responses that did not identify SORs; responses that indicated sourcing location
without complete supporting information from the supply chain; and organizations that were identified as
SORs, but not verified as such through further analysis and research.
(d) When SOR data was obtained, we used the existing SOR database of the third-party service provider, the
CFSI’s list of SORs, internet research, and other resources (e.g., government databases and industry and
trade organization lists) to verify whether entities identified as SORs are actually 3TG SORs. Where we
found that an entity named as a SOR was not directly involved in the smelting or recycling of the relevant
metal, the Supplier that provided this information was contacted to attempt to obtain additional information
about the origin of the materials or information about its direct suppliers. If contact information was
provided, or could be obtained, for the entity listed as a SOR, the listed entity was also contacted to obtain
additional information about the origin of materials used. We also investigated Supplier statements that a
3
SOR did not source from the Covered Countries when the stated sourcing location (country of mine origin)
was not a known reserve for the given metal.
OECD Guidance Step Three: Design and implement a strategy to respond to identified risks
(a) We reported the findings of our supply chain risk assessment as outlined in this CMR to our General
Counsel and supply chain senior leadership.
(b) We took such risk mitigation efforts as we deemed to be appropriate based on the findings of our supply
chain risk assessment. Our risk mitigation efforts with respect to our 2014 supply chain were determined
by the particular facts and circumstances and risks identified.
(c) To mitigate the risk that our necessary 3TG benefit armed groups, we intend to engage in the additional
measures discussed under “Addressing Identified Risks” below.
OECD Guidance Step Four: Carry out independent third-party audit of supply chain due diligence at identified
points in the supply chain
In connection with our due diligence, we utilized information made available by the CFSI, London Bullion
Market Association, and Responsible Jewellery Council concerning independent third-party audits of
smelters and refiners.
OECD Guidance Step 5: Report on supply chain due diligence
We filed a Form SD and this Conflict Minerals Report with the Securities and Exchange Commission and
made available on our website this Conflict Minerals Report and the Form SD.
Summary of Findings
A total of 557 Tier 1 Suppliers were identified as in-scope for conflict mineral regulatory purposes and contacted as
part of the RCOI process. The response rate among these Suppliers was 100%. 24% of the Suppliers indicated one
or more of the conflict minerals as necessary to the functionality or production of the Covered Products.
Based on the information provided by our Tier 1 Suppliers and our own due diligence efforts with known smelters
and refiners through December 31, 2014, we believe that the facilities that may have been used to process the
conflict minerals in the Covered Products include the 294 verified SORs listed in Annex I. Based on review of
certain SOR databases, there was an indication of DRC sourcing for 36 out of the 294 verified SORs. Of the 36
SORs with an indication of sourcing in the Covered Countries, 31 were certified as DRC Conflict Free by CFSI.
Notwithstanding the due diligence process described above, we do not have sufficient information from Tier 1
Suppliers or other sources to conclusively determine whether any 3TG originating in the Covered Countries was
included in our Covered Products and, if so, whether the 3TG was from recycled or scrap sources, and whether or
not these conflict minerals directly or indirectly financed or benefited armed groups in the Covered Countries.
However, based on the information provided by our Tier 1 Suppliers and SORs, as well as from the CFSI and other
sources, we believe that the countries of origin of the conflict minerals contained in our Covered Products include
the countries listed in Annex II below, as well as recycled and scrap sources.
Addressing Identified Risks
In 2014, our efforts continued to be focused on collecting and disseminating information from our Tier 1 Suppliers
on their sourcing practices using the Template and creating a database for that information.
4
In the 2015 reporting year, we will continue our supplier engagement process with an aim to decrease the number of
Covered Products with 3TG of indeterminate origin. We expect that our 2015 efforts will include:
•
•
•
Reviewing and updating the list of Covered Products and associated Tier 1 Suppliers designated as in-scope
as needed;
Re-engaging each in-scope Tier 1 Supplier to verify and update sourcing information as needed; and
Continuing to work with Suppliers to gain information about supply chain actors closer upstream to the
smelter or refiner to facilitate the exchange of information on the origin of 3TG.
We intend to undertake the following steps during the 2015 reporting year to further mitigate the risk that our
Covered Products contain conflict minerals that benefit armed groups in the Covered Countries:
•
•
•
Continuing to engage with Tier 1 Suppliers to obtain current, accurate and complete information about the
supply chain;
Encouraging Tier 1 Suppliers to implement responsible sourcing and to encourage their smelters and
refiners to obtain a “conflict-free” certification from an independent, third-party auditor; and
Engaging in industry initiatives encouraging “conflict-free” supply chains.
5
ANNEX I
Metal
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold/Tin
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold/Tungsten
Gold
Gold
Smelter or Refiner Name
Advanced Chemical Company
Aida Chemical Industries Co. Ltd.*
Allgemeine Gold-und Silberscheideanstalt A.G.*
Almalyk Mining and Metallurgical Complex (AMMC)
AngloGold Ashanti Córrego do Sítio Minerção*
Argor-Heraeus SA*
Asahi Pretec Corporation*
Asaka Riken Co Ltd
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. *
Aurubis AG*
Baiyin Nonferrous Group Co., Ltd.
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)†
Bauer Walser AG
Boliden AB*
C. Hafner GmbH + Co. KG*
CCR Refinery - Glencore Canada Corporation*
Caridad
Cendres + Métaux SA
Chimet S.p.A.*
China National Gold Group Corporation
China Nonferrous Metal Mining (Group) Co., Ltd.
Chugai Mining
Codelco
Colt Refining
Daejin Indus Co. Ltd
Daye Non-Ferrous Metals Mining Ltd.
Do Sung Corporation
Doduco
Dowa Mining Co., Ltd.*
Eco-System Recycling Co., Ltd.*
Eldorado Gold Corporation
FSE Novosibirsk Refinery
Faggi S.p.A.
Gansu Seemine Material Hi-Tech Co Ltd
Geib Refining Corp
Guangdong Jinding Gold Limited
Hangzhou Fuchunjiang Smelting Co., Ltd.
Heimerle + Meule GmbH*
Heraeus Ltd. Hong Kong*
Heraeus Precious Metals GmbH & Co. KG*
Hunan Chenzhou Mining Group Co., Ltd.
Hwasung CJ Co. Ltd
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
6
Metal
Gold
Gold
Gold
Gold
Gold/Tin
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold/Tin
Gold/Tantalum
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Smelter or Refiner Name
Ishifuku Metal Industry Co., Ltd.*
Istanbul Gold Refinery*
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
JSC Uralelectromed*
JX Nippon Mining & Metals Co., Ltd.*
Japan Mint*
Jiangxi Copper Company Limited
Johnson Matthey Inc*
Johnson Matthey Ltd*
Kazakhmys plc
Kazzinc Inc.*
Kennecott Utah Copper LLC*
Kojima Chemicals Co., Ltd*
Korea Metal Co. Ltd
Kyrgyzaltyn JSC
L' azurde Company For Jewelry*
LS-NIKKO Copper Inc.*
Lingbao Gold Company Ltd.
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
Luoyang Zijin Yinhui Metal Smelt Co Ltd
Materion*
Matsuda Sangyo Co., Ltd.*
Met-Mex Peñoles, S.A.*
Metalor Technologies (Hong Kong) Ltd*
Metalor Technologies (Singapore) Pte. Ltd.*
Metalor Technologies SA*
Metalor USA Refining Corporation*
Mitsubishi Materials Corporation*
Mitsui Mining and Smelting Co., Ltd.*
Moscow Special Alloys Processing Plant
Nadir Metal Rafineri San. Ve Tic. A.ª.*
Navoi Mining and Metallurgical Combinat
Nihon Material Co. LTD*
OJSC Kolyma Refinery
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC
Krastvetmet)*
Ohio Precious Metals, LLC*
Ohura Precious Metal Industry Co., Ltd*
PAMP SA*
PT Aneka Tambang (Persero) Tbk*
PX Précinox SA*
Penglai Penggang Gold Industry Co Ltd
Prioksky Plant of Non-Ferrous Metals
Rand Refinery (Pty) Ltd*
Royal Canadian Mint*
SAMWON METALS Corp.
7
Metal
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold/Tungsten
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Gold
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Smelter or Refiner Name
SEMPSA Joyería Platería SA*
SOE Shyolkovsky Factory of Secondary Precious Metals
Sabin Metal Corp.
Samduck Precious Metals
Schöne Edelmetaal B.V.*
Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Sichuan Tianze Precious Metals Co., Ltd*
So Accurate Group, Inc.
Solar Applied Materials Technology Corp.*
Sumitomo Metal Mining Co., Ltd.*
Super Dragon Technology Co., Ltd.
Tanaka Kikinzoku Kogyo K.K.*
The Great Wall Gold and Silver Refinery of China
The Refinery of Shandong Gold Mining Co. Ltd*
Tokuriki Honten Co., Ltd*
TongLing Nonferrous Metals Group Holdings Co., Ltd.
Torecom
Umicore Brasil Ltda*
Umicore Precious Metals Thailand*
Umicore SA Business Unit Precious Metals Refining*
United Precious Metal Refining, Inc.*
Valcambi SA*
Western Australian Mint trading as The Perth Mint*
Yamamoto Precious Metal Co., Ltd.
Yantai Guodasafina High-tech Environmental Refinery CO., Ltd.
Yokohama Metal Co Ltd
Yunnan Copper Industry Co Ltd
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Zijin Mining Group Co. Ltd*
AMG Advanced Metallurgical Group
Changsha South Tantalum Niobium Co., Ltd.*
Conghua Tantalum and Niobium Smeltry*
D Block Metals, LLC*
Duoluoshan Sapphire Rare Metal Co., Ltd.*
Exotech Inc.*
F&X Electro-Materials Ltd.*
Global Advanced Metals Aizu*
Global Advanced Metals Boyertown*
Guangdong Zhiyuan New Material Co., Ltd.*
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch*
H.C. Starck Co., Ltd.*
H.C. Starck GmbH Goslar*
H.C. Starck GmbH Laufenburg*
H.C. Starck Hermsdorf GmbH*
H.C. Starck Inc.*
8
Metal
Tantalum
Tantalum/Tungsten
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum/Tin
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tantalum
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Smelter or Refiner Name
H.C. Starck Ltd.*
H.C. Starck Smelting GmbH & Co.KG*
Hengyang King Xing Lifeng New Materials Co., Ltd.*
Hi-Temp Specialty Metals, Inc.*
Jiangxi Dinghai Tantalum & Niobium Co., LTD*
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Jiujiang Tanbre Co., Ltd.*
KEMET Blue Metals*
Kemet Blue Powder*
King-Tan Tantalum Industry Ltd*
LSM Brasil S.A.*
Metallurgical Products India (Pvt.) Ltd.*
Mineração Taboca S.A.*
Molycorp Silmet A.S.*
Ningxia Orient Tantalum Industry Co., Ltd.*
Plansee SE Liezen*
Plansee SE Reutte*
QuantumClean*
RFH Tantalum Smeltry Co., Ltd*
Shanghai Jiangxi Metals Co., Ltd.
Solikamsk Metal Works*
Taki Chemicals*
Telex*
Ulba*
Yichun Jin Yang Rare Metal Co., Ltd*
Zhuzhou Cement Carbide*
Alpha*
CNMC (Guangxi) PGMA Co. Ltd.
CV Duta Putra Bangka*
CV Gita Pesona
CV Makmur Jaya
CV Nurjanah
CV Serumpun Sebalai
CV United Smelting
China Rare Metal Materials Company*
China Tin Group Co., Ltd.
Cooper Santa
Empresa Metallurgica Vinto*
Estanho de Rondônia S.A.
Feinhutte Halsbrucke GmbH
Fenix Metals
Foshan Nanhai Tong Ding Metal Company. Ltd.
Gejiu Kai Meng Industry and Trade LLC
Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Gejiu Zi-Li
9
Metal
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Smelter or Refiner Name
Huichang Jinshunda Tin Co. Ltd
Jean Goldschmidt International SA
Jiangxi Nanshan
Kai Unita Trade Limited Liability Company
Kovohutì Pøíbram
Linwu Xianggui Smelter Co
Magnu's Minerais Metais e Ligas LTDA*
Malaysia Smelting Corporation (MSC)*
Materials Eco-Refining CO., LTD
Melt Metais e Ligas S/A*
Metallo Chimique*
Minsur*
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Novosibirsk Integrated Tin Works
O.M. Manufacturing (Thailand) Co., Ltd.
O.M. Manufacturing Philippines, Inc.
Operaciones Metalurgical S.A.*
POSCO
PT ATD Makmur Mandiri Jaya*
PT Alam Lestari Kencana
PT Artha Cipta Langgeng
PT Babel Inti Perkasa*
PT Babel Surya Alam Lestari
PT Bangka Kudai Tin
PT Bangka Putra Karya*
PT Bangka Timah Utama Sejahtera
PT Bangka Tin Industry*
PT Belitung Industri Sejahtera*
PT BilliTin Makmur Lestari
PT Bukit Timah*
PT DS Jaya Abadi*
PT Donna Kembara Jaya
PT Eunindo Usaha Mandiri*
PT Fang Di MulTindo
PT HANJAYA PERKASA METALS
PT HP Metals Indonesia
PT Inti Stania Prima
PT Justindo
PT Karimun Mining
PT Koba Tin
PT Mitra Stania Prima*
PT Panca Mega Persada*
PT Pelat Timah Nusantara Tbk
PT Prima Timah Utama*
PT Refined Banka Tin*
10
Metal
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tin
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Smelter or Refiner Name
PT Sariwiguna Binasentosa*
PT Seirama Tin investment
PT Stanindo Inti Perkasa*
PT Sumber Jaya Indah
PT Supra Sukses Trinusa
PT Tambang Timah*
PT Timah (Persero), Tbk*
PT Tinindo Inter Nusa*
PT Tommy Utama
PT WAHANA PERKIT JAYA*
PT Yinchendo Mining Industry
Poongsan Corporation
RUI DA HUNG
Senju Metal Industry Co., Ltd.
Shangrao Xuri Smelting Factory
Soft Metais, Ltda.
Thaisarco*
VQB Mineral and Trading Group JSC
White Solder Metalurgia e Mineração Ltda.*
Xianghualing Tin Co., Ltd.
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Yunnan Tin Company Limited*
A.L.M.T. Corp.
Beijing Tian-Long Tungsten & Molybdenum Co., Ltd.
Chenzhou Diamond Tungsten Products Co., Ltd.
Chongyi Zhangyuan Tungsten Co., Ltd.
Dayu Jincheng Tungsten Industry Co., Ltd.
Dayu Weiliang Tungsten Co., Ltd.
Fujian Jinxin Tungsten Co., Ltd.
Ganxian Shirui New Material Co., Ltd.
Ganzhou Haichuang Tungsten Industry Co., Ltd.
Ganzhou Huaxing Tungsten Products Co., Ltd.*
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Ganzhou Seadragon W & Mo Co., Ltd.*
Global Tungsten & Powders Corp.*
Golden Egret Special Alloy Co. Ltd
Guangdong Xianglu Tungsten Industry Co., Ltd.
H.C. Starck GmbH
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.*
Japan New Metals Co., Ltd.*
Jiangsu Hetian Technological Material Co., Ltd
Jiangxi Gan Bei Tungsten Co., Ltd.*
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp
11
Metal
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Tungsten
Smelter or Refiner Name
Jiangxi Richsea New Materials Co., Ltd.
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Jiangxi Tungsten Industry Group Co Ltd
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Jiangxi Yaosheng Tungsten Co., Ltd.
Kennametal Fallon
Kennametal Huntsville
Malipo Haiyu Tungsten Co., Ltd.*
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tejing (Vietnam) Tungsten Co., Ltd.
Vietnam Youngsun Tungsten Industry Co., Ltd.*
Voss Metals Company, Inc.
Wolfram Bergbau und Hütten AG*
Wolfram Company CJSC
Xiamen Honglu Tungsten Molybdenum Industry Co.Ltd
Xiamen Tungsten (H.C.) Co., Ltd.*
Xiamen Tungsten Co., Ltd.*
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
*Smelter or refiner certified by the Conflict-Free Sourcing Initiative
†Smelter or refiner certified by the London Bullion Market Association
12
ANNEX II
Countries of Origin
Angola
Argentina
Armenia
Australia
Austria
Belarus
Belgium
Bermuda
Bolivia
Brazil
Burundi
Canada
Chile
China
Democratic Republic of the Congo
Estonia
Ethiopia
France
Germany
Ghana
Greece
Guinea
Guyana
Hong Kong
India
Indonesia
Italy
Japan
Jersey
Kazakhstan
Kyrgyzstan
Laos
Malaysia
Mali
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
Niger
Nigeria
Papua New Guinea
Peru
Philippines
Poland
Portugal
Romania
Russia
Rwanda
Saudi Arabia
Sierra Leone
Singapore
South Africa
South Korea
Spain
Suriname
Sweden
Switzerland
Taiwan
Tajikistan
Tanzania
Thailand
Turkey
United Arab Emirates
United Kingdom
United States
Uzbekistan
Vietnam
Zambia
Zimbabwe
13